Poland’s e-invoicing system KSeF comes into force from January 1, 2022.

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On Friday October 1, 2021, the Polish Sejm adopted an amendment to the VAT act, implementing the National System of e-Invoices (KSeF) which will enter into force on January 1, 2022.


Starting from 2022, the taxpayers who issue electronic invoices through KSeF will receive a VAT refund in 40 days instead of 60 days, only if they meet required conditions among which the most relevant are:


  • The taxpayer used a new invoice template for the entire VAT settlement period
  • The entrepreneur or the business is already registered as a VAT-payer and has been active for a period of more than 12 months
  •  There is a refund limit to safeguard abuse. The amount of VAT (input tax) or the amount of VAT not settled in previous accounting periods, shown in the VAT return declaration, may not exceed 3 000 PLN


KSeF enables issuing and sharing structured invoices. In the initial period, structured invoices will function in business transactions as one of the accepted forms of documenting transactions, in addition to paper (physical) invoices and electronic invoices currently used in business transactions. E-invoices are therefore voluntary but not yet compulsory.


What format should an e-invoice follow?

A structured invoice has the xml format according to the structure of the e-Invoice (FA_VAT). Some structures of e-invoices can already be downloaded here.


How do you issue an invoice at the KSeF?

You can issue structured invoices:

  • with the use of free tools provided by the Ministry of Finance
  • using commercial programs


What are the stages of introducing KSeF in Poland?


Stage 1

From October to December 2021, a pilot is conducted  with the participation of taxpayers. Details on testing can be found in the KSeF test zone ta



Stage 2

From January 1, 2022,  the National System of e-Invoices will be introduced as a voluntary solution. From now on, taxpayers will be able to issue structured invoices under the National System of e-Invoices (KSeF).


Stage 3

After obtaining the derogation decision of the European Commission, a plan to make the National System of e-Invoices an obligatory solution is expected to be implemented in year 2023.


From January 2022 the taxpayers can use the KSeF voluntarily while from 2023, the Polish government will make using KSeF mandatory. 



Do taxpayers have to join the KSeF?

In the first stage of the FSC implementation, a taxpayer will decide whether to issue a structured invoice in the FSC or to stick to the solution used so far. As of year 2022, e-invoices are voluntary but not yet compulsory.


Who can use the KSeF?

  • Entrepreneurs registered as active VAT taxpayers
  • Entrepreneurs exempt from VAT
  • Taxpayers identified in Poland for the special EU OSS procedure, having a Polish tax identification number NIP


Source: orka.sejm.gov.pl, podatki.gov.pl


NOTE: The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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